We declare that our company complies with laws and regulations concerning protection of personal information and other norms for personal information on our customers, business partners, etc. that our company will use for our business, establishes voluntary rules and a structure while also considering international movements, sets the following privacy policies, and executes and maintains them.
- To execute this declaration, our company sets “personal information protection rules,” familiarizes our employees (including all executives, employees, part-timers and dispatched workers) and other concerned parties with the rules, performs and improves and maintains the rules.
- Our company takes appropriate information security measures, such as measures against unauthorized access and measures against computer viruses, in order to prevent personal information from being lost, damaged, falsified or leaked, etc.
- In acquiring personal information, our company uses legitimate and fair means, and does not use any illicit method. If receiving personal information, our company clearly shows our intent of acquiring the information and the intended use, etc. or notifies them to the individual as the owner of the personal information (hereafter called “Individual”), or publish them, before acquiring the information.
- If indirectly obtaining personal information, our company confirms whether or not the provider of the information to be obtained has appropriately acquired it from the Individual.
- Our company confirms that the Individual has the rights such as those to disclose his/her personal information, correct it, suspend the use of it, and erase it, and appropriately responds to such a request by the Individual.
- If jointly using personal information with a third party or entrusting personal information to a third party in order to commission our business to the party, our company investigates the third party, concludes a necessary agreement with the party, and takes legally required measures.
February 8, 2008
Haruhisa Okamura, CEO, Adways Inc.
Handling of Personal Information
1.Acquisition of personal information
Our company acquires personal information of the customer to the extent necessary to provide services that our company provides. Our company appropriately acquires personal information, and does not acquire personal information through feigning or any other illicit means. If receiving personal information from the customer, our company clearly shows or notifies our intent of acquiring the information to the customer, or publishes it. In addition, our company does not acquire, use or provide personal information that contains the following.
- Matters related to any thought, belief or religion
- A race, ethnic group, family origin, legal domicile (excluding information on the prefecture), physical/mental disorder, criminal record, or any other matter that may cause social discrimination
- Matters related to workers’ right to organize of, collective bargaining, or any other act of collective action
- Matters related to participation in collective demonstration, exercise of the right of petition, or exercise of any other political right
- Matters related to healthcare or sex life
2.Use and handling of personal information
Only those granted with authority according to a specific operation shall use the acquired personal information of the customer within the scope of the intended use only if it is necessary to use the information for the execution of the operation. In addition, such information may be mutually used for our company’s respective services, etc.
Our company handles personal information with care of a good manager in accordance with the Act on the Protection of Personal Information (hereafter called “Personal Information Protection Act”).
3.Definition of personal information
Our company recognizes personal information as information on living individuals defined in the Personal Information Protection Act (information that enables us to identify a particular individual such as a name and address), information such as an e-mail address, access record, user ID, password and credit card that are used in connection with a particular individual, and attribute information related to an individual such as taste, family makeup and date of birth integrated with personal information.
4.Cookies, IP address information, mobile identification numbers
Our company does not recognize cookies, IP address information, and mobile identification numbers (individual identification numbers) as personal information since it is impossible to identify a particular individual with such information alone. However, if such information is used as integrated with personal information, our company considers even such information as personal information since it enables us to identify a particular individual.
In services that our company provides, if our company uses a cookie, IP address information or mobile identification number (individual identification number), our company intends to disclose the purpose and method even if such information does not enable us to identify a particular individual.
5.Notification and identification of the intended use of personal information
If our company acquires and handles personal information of the customer, our company identifies the intended use as much as possible, clearly shows or notifies the intended use to the customer, or publishes it in advance. However, this does not apply in the following cases.
- The life, body, property or other rights and interests of the Individual or a third party may be harmed.
- Our company’s rights or legitimate interests may be harmed.
- It is necessary to cooperate in the fulfilment of a legally defined business by a national agency or a local government, and the above said activity of our company may interfere with the fulfillment of the business.
- The intended use is considered as obvious based on the situation of the acquisition.
6.Scope and change of the intended use of personal information
Our company does not handle personal information beyond the scope necessary to achieve the intended use without consent of the Individual. However, this does not apply in the following cases.
- Handling of such information is permitted by law.
- Handling of such information is urgent, and it is difficult to obtain consent of the Individual.
- It is necessary to cooperate in the fulfilment of a legally defined business by a national agency or a local government, and failure to obtain consent of the Individual may interfere with the fulfillment of the business.
- Personal information is handled to the extent that an individual cannot be identified.
If our company is to change the intended use of personal information, our company does not change it beyond the extent that the change is reasonably regarded as having considerable relevance to the intended use before change, and notifies the changed intended use to the Individual or publish it. The Individual has the option of using personal information for the changed intended use.
7.Provision of personal information
Our company does not provide personal information of the customer to a third party without permission of the Individual in principle.
However, our company may provide personal information to a third party in the following cases.
- Our company has obtained consent of the Individual.
- The life, body, property or other rights and interests of the Individual or a third party may be harmed, and it is difficult to obtain consent of the Individual.
- The court, public prosecutor’s office, police, tax office, bar association or an agency with authority equivalent to these requires our company to disclose personal information.
- Our company commissions part or the whole of a business that our company operates to a third party within the scope necessary to achieve the intended use.
- Our company discloses personal information to those who are obliged to keep secret for our company, such as a lawyer, accountant, and the Japan Affiliate Service Kyokai (Association).
- Our company entrusts personal information of a user who uses a paid service to a payment system company or credit company, to which our company commissions our business (concluding a confidentiality agreement), with the aim of charging the user who uses the paid service with a usage fee.
- Provision of personal information is required for exercising our company’s right.
- Personal information is statistically processed in a manner that the individual cannot be identified.
- Our company discloses personal information to the person inheriting our business when our business is inherited for business transfer or other reasons.
- Provision of personal information is permitted under the Personal Information Protection Act or other laws and regulations.
- The following matters are announced or published in advance.
- Inclusion of the provision of personal information to a third party in the intended use
- Items of data provided to a third party or a means/method of provision
8.Supervision of the consignee
If our company commissions part or the whole of the handling of personal information to a third party, our company requests the consignee to sign an agreement including confidentiality or agree to a clause that our company establishes, and conducts necessary and appropriate supervision of the consignee so that personal information is safely managed at the consignee.
9.Disclosure, correction, suspension of use, and erasure of personal information
If the customer desires to disclose, correct, make an addition to, suspend use of, suspend provision of, or erase his/her personal information, etc., our company conducts identification and checks authentication of the information through our company’s prescribed procedures, and promptly performs an action such as disclosure, correction and erasure of the personal information provided by the customer. However, if any of the following items applies, our company may not respond to the customer’s request for disclosure, correction, addition, suspension of use, suspension of provision or erasure. In such a case, our company notifies the Individual to that effect and explains the reason.
- The life, body, property or other rights and interests of the Individual or a third party may be harmed.
- Appropriate conduct of the company’s business may be significantly interfered with.
- Such an act may violate laws or regulations.
If the customer desires to disclose, correct, make addition to, suspend use of, suspend provision of, or erase his/her personal information, etc., contact the following contact point.
10.Arbitrariness of providing personal information
For the websites that our company operates, our company is doing our best to prevent unauthorized external access and information leakage by managing the websites using a special encryption communication technique called SSL and using a dedicated server protected with a security system called a Firewall for the registration of the customer’s valuable personal information.
Our company has established the following dedicated contact point for inquiries about the disclosure, correction, addition, suspension of use, erasure, etc. of personal information, request for disclosing personal information, and handling of other personal information, in order to facilitate appropriate and prompt response.
● Dedicated contact point ●
Contact point for personal information: email@example.com Compliance Office, Adways Inc.
38th Floor, Sumitomo Fudosan Shinjuku Grand Tower, 8-17-1, Nishi-shinjuku, Shinjuku-ku, Tokyo, 160-6138, Japan
* Please note that we cannot receive any request or inquiry made through direct visit to our office.
* Our request to customers
- In the websites that our company operates, customers’ registered information may be protected with IDs and passwords. The customers must manage their IDs and passwords at their own responsibility.
- For safe use of the services that our company provides and the websites that our company operates, please do not indiscriminately post personal information of others or the customer on the websites that our company operates.